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CONTINGENT LIABILITIES AND ENVIRONMENTAL RESERVES
12 Months Ended
Oct. 31, 2022
Environmental Remediation Obligations [Abstract]  
CONTINGENT LIABILITIES AND ENVIRONMENTAL RESERVES CONTINGENT LIABILITIES AND ENVIRONMENTAL RESERVES
Litigation-related Liabilities
The Company may become involved from time-to-time in litigation and regulatory matters incidental to its business, including governmental investigations, enforcement actions, personal injury claims, product liability, employment health and safety matters, commercial disputes, intellectual property matters, disputes regarding environmental clean-up costs, litigation in connection with acquisitions and divestitures, and other matters arising out of the normal conduct of its business. The Company intends to vigorously defend itself in such litigation. The Company does not believe that the outcome of any pending litigation will have a material adverse effect on its consolidated financial statements.
The Company will accrue for contingencies related to litigation and regulatory matters if it is probable that a liability has been incurred and the amount of the loss can be reasonably estimated. Because litigation is inherently unpredictable and unfavorable resolutions can occur, assessing contingencies is highly subjective and requires judgments about future events. The Company regularly reviews contingencies to determine whether its accruals are adequate. The amount of ultimate loss may differ from these estimates.
Since 2017, two reconditioning facilities in the Milwaukee, Wisconsin area that are or were owned by Container Life Cycle Management LLC ("CLCM"), the Company’s U.S. reconditioning joint venture, have been subject to investigations conducted by federal, state and local governmental agencies concerning, among other matters, potential violations of environmental laws and regulations. As a result of these investigations, the United States Environmental Protection Agency (“U.S. EPA”) and the Wisconsin Department of Natural Resources (“WDNR”) have issued notices of violations to the Company and CLCM regarding alleged violations of certain federal and state environmental laws and regulations. The U.S. EPA and the WDNR have rescinded the notices of violations relating to the Company and have reached agreement with CLCM on a proposed consent decree that would resolve these investigations and proceedings against CLCM (the “Proposed CLCM Consent Decree”). On November 30, 2022, the U.S. EPA and the WDNR filed an action in the U.S. District Court, Eastern District of Wisconsin, seeking the Court’s approval of the Proposed CLCM Consent Decree. Under the Proposed CLCM Consent Decree, CLCM, without admitting any wrongdoing, has agreed to modify certain existing operational practices, install and operate specific environmental controls and pay civil penalties of approximately $1.6 million. The Proposed CLCM Consent Decree is not final and effective unless and until approved by the Court.
Environmental Reserves
As of October 31, 2022 and October 31, 2021, the Company has accrued $9.8 million and $11.0 million, respectively, for the Diamond Alkali Superfund Site. It is possible that there could be resolution of uncertainties in the future that would require the Company to record charges, which could be material to future earnings.
Aside from the Diamond Alkali Superfund Site, other environmental reserves of the Company as of October 31, 2022 and October 31, 2021 included $9.2 million and $8.5 million, respectively, for its various facilities around the world.
As of October 31, 2022 and October 31, 2021, the Company's environmental reserves were $19.0 million and $19.5 million, respectively. These reserves are principally based on environmental studies and cost estimates provided by third parties, but also take into account management estimates. The estimated liabilities are reduced to reflect the anticipated participation of other potentially responsible parties in those instances where it is probable that such parties are legally responsible and financially capable of paying their respective shares of relevant costs. For sites that involve formal actions subject to joint and several liabilities, these actions have formal agreements in place to apportion the liability.